We recently stopped offering credit life insurance for our loans. Our Financial Services area does not offer this product either but would offer a term life insurance policy as an alternative. If the customer comes to the loan officer and inquire about insurance, we would refer them to the Financial Services area so that they can shop for term life insurance products.
Since we are not offering the credit life insurance product anymore and our Financial Services area doesn't sell it, are we still required to provide the Federal Credit Application Insurance Disclosure to our customers? I would think that we don't need to unless a customer inquires about insurance, then we would need the disclosure to be provided to the customer.
What is your opinion on this?

Do you have a form letter template or suggested text that can be used when we receive a legal issue from outside a jurisdiction we would otherwise have
to honor, stating we will not be responding and that legal issues must come from our areas we are subject to?

We suspect a customer is being used as a mule and recently received a large ACH credit. The next day, he wanted to send an international wire with the
proceeds from the credit. His explanation of where the funds came from and what they are being used for has changed several times; therefore, we froze
the account and have the funds from the ACH credit on hold. Since we suspect he received the funds fraudulently, are we under any obligation to
release these to our customer?

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